On 24 January 2019 Switzerland and Ukraine signed a Protocol of Amendment to the Double Taxation Convention (DTA) in the area of taxes on income and assets.
The Protocol of Amendment to the DTA with Ukraine implements the minimum standards in double taxation agreements and also adapts the DTA to the current treaty policy of the two states.
For the taxation of dividends, a qualified interest of 10% (previously 20%) will suffice in future. Furthermore, dividends paid to the National Bank or to the Contracting States are taxable only in the State of residence. Finally, a residual tax rate of 5% is now provided for on both interest and royalties.
The Protocol of Amendment also contains an abuse clause and an arbitration clause. Finally, the agreement contains an administrative assistance clause in accordance with international standards on the exchange of information on request.
